Under a group disability insurance plan, the cost of contributions was allocated as:
- Life, accidental death and dismemberment insurance: $8/month
- Short-term disability insurance: $25/month
- Long-term disability insurance: $15/month
- Medical care insurance: $60/month
The collective agreement stated, without elaboration, that the employer's contribution for all employees was 50% of the cost of the group disability plan, with the other 50% of the contributions being paid by the employees. The employee contributions were allocated by the employer to equal 100% of the above costs of the long term and short term disability insurance and life insurance, with the balance ($6) allocated to the medical insurance ($6).
CRA stated:
… [T]he employer's contribution for all employees is 50% of the cost of the group disability plan while the other 50% of the contributions are borne by the employees. The fact that an employer arbitrarily allocates the contributions collected from employees so that they constitute 100% of the contributions paid to the long-term and short-term disability insurance plans does not make the disability insurance plan a fully employee-funded plan. … [T]he legal obligation to pay premiums is shared equally between the employer and the employees. Consequently, the benefits received by an employee from the long- and short-term disability plan are taxable in computing the employee's income pursuant to paragraph 6(1)(f) … .